The Tax Break | Uncertain tax positions

Osborne Clarke.TV Podcasts

In our latest tax break podcast, partner Ian Hyde is joined by Heather Self of accountants Blick Rothenberg to discuss HMRC's proposal to require large businesses to report uncertain tax positions to HMRC. This is intended to alert the tax authorities to large businesses taking an aggressive/optimistic approach to statutory interpretation. Although large businesses often do in practice already disclose significant uncertainty upfront, HMRC is consulting on bringing in this new requirement in April 2022. This podcast covers which companies will be subject to this new requirement (if it is brought in), what exactly is meant by "uncertain", what threshold is envisaged and how the transitional period will be dealt with. There is also a discussion about which groups of companies might face the biggest challenge from this change.